United States securities and exchange commission logo
March 19, 2024
Douglas K. Howell
Chief Financial Officer
Arthur J. Gallagher & Co.
2850 Golf Road
Rolling Meadows, IL 60008-4050
Re: Arthur J. Gallagher
& Co.
Form 10-K for the
Fiscal Year Ended December 31, 2023
File No. 001-09761
Dear Douglas K. Howell:
We have limited our review of your filing to the financial
statements and related
disclosures and have the following comment.
Please respond to this letter within ten business days by
providing the requested
information or advise us as soon as possible when you will respond. If
you do not believe a
comment applies to your facts and circumstances, please tell us why in
your response.
After reviewing your
response to this letter, we may have additional comments.
Form 10-K for the Fiscal Year Ended December 31, 2023
Notes to Consolidated Financial Statements
5. Change in Presentation of Fiduciary Assets and Liabilities, page 89
1. We note your disclosure
that you revised your balance sheet and statement of cash flows
presentation to
separately identify and present fiduciary assets and liabilities and that you
also made certain
revisions to fiduciary balances related to the former Willis Re
operations from gross
to net presentation to align with your accounting policy and
presentation. For each
change and revision reflected in the financial statements, please
address the items
below.
Clarify whether you
concluded that your prior presentation (e.g., gross to net,
statement of cash
flow classification, etc.) was an error and how you considered ASC
250 in your
determination.
To the extent
applicable, provide us with a detailed description of any error(s),
including but not
limited to who identified them, when and how, whether they were
the result of
control deficiencies, as well as your assessment of materiality,
individually and
in the aggregate, that addresses both qualitative and quantitative
Douglas K. Howell
Arthur J. Gallagher & Co.
March 19, 2024
Page 2
factors and consideration of guidance in ASC 250, SAB 99, and
management's
assessment of design and effectiveness of ICFR.
Provide us with an accounting analysis, citing authoritative
literature, explaining your
presentation before and after implementing these changes to your
presentation. For
example, explain why net change in fiduciary assets and
liabilities appears to have
moved from operating activities to financing activities within
the statement of cash
flows.
In closing, we remind you that the company and its management are
responsible for the
accuracy and adequacy of their disclosures, notwithstanding any review,
comments, action or
absence of action by the staff.
Please contact Cara Lubit at 202-551-5909 or Robert Klein at
202-551-3847 with any
questions.
FirstName LastNameDouglas K. Howell Sincerely,
Comapany NameArthur J. Gallagher & Co.
Division of
Corporation Finance
March 19, 2024 Page 2 Office of
Finance
FirstName LastName